United States v. Sturm

John Sturm (defendant) financed an aircraft with WCIS, secured partly by the plane's logbooks, but after missing payments WCIS repossessed the plane without the logbooks and couldn't get a fair auction price without them. When WCIS asked for the logbooks back, Sturm said he didn't know where they were but offered to return them for a $20,000 fee. WCIS looped in the FBI, told Sturm the fee was approved, and agents posing as WCIS officers arrested Sturm once he produced the books. Sturm was convicted of attempted extortion under the Hobbs Act. At trial, the judge instructed the jury on a claim-of-right defense but also told jurors the government didn't need to prove Sturm knew his conduct was illegal. Sturm appealed.